On 25 June 2023, the Federal Administration of Public Revenues (“AFIP”) published in the Official Gazette General Resolution 5391/2023 (the “Resolution”) which creates a new extraordinary advance payment of income tax.
The most relevant aspects of the Resolution are as follows:
- The Extraordinary Advance shall be paid by those companies that, in the sworn declarations for the periods 2022 or 2023 as appropriate, meet the following conditions:
- Have reported taxable income equal to or greater than AR$600,000,000 without deduction of prior period losses, and
- Have not determined income tax.
- Companies with an income tax exemption certificate are excluded.
- To determine the Extraordinary Contribution you must:
- Consider the tax return for the period 2022 for taxpayers whose fiscal years ended between August and December 2022, and
- Consider the tax return for the period 2023 in the case of taxpayers whose tax year ended between January and June 2023.
- Taxpayers closing between August and December 2022 will be able to compute the Extraordinary Contribution as payment on account of Income Tax for the 2023 period. Taxpayers closing between January and June 2023 will be able to compute the Extraordinary Contribution as a payment on account of Income Tax for the 2024 tax year.
- The amount of the payment on account shall be 15% of the taxable result of the previous tax period without taking into account the deduction of losses.
The Extraordinary Contribution is payable in three equal and consecutive installments, on the dates indicated below:
|End of the financial year||Due date payments N°1, N°2 and N°3|
|August to December 2022||22 August/September/October 2023, respectively|
|January to May 2023||22 December 2023 and January/February 2024, respectively|
|June 2023||22 January/February/March 2024, respectively|
|July 2023||22 February/March/April 2024, respectively|